Crystal Palace Campiagn UDPproof

Bromley Unitary Development Plan

Proof of Philip Kolvin

Crystal Palace Park

Crystal Palace Campaign

Section 18

Go forth into the Park, take glass and iron, and - beauty wedding strength - produce the Industrial Hall of Nations.

Punch, of the Crystal Palace.

18

Conservation: Objections to Chapter 6 policies. (0296I, 0297I, 0296J, 0297J)

18.1

A further opportunity for protection is lost in policy BE11, which deals with historic parks and gardens. The policy states that the Council will seek to ensure that such places are appropriately managed, improved and maintained, and that development proposals should have due regard to their special characteristics and interest. This misses out a crucial verb in national planning policy PPG15: "protect". Paragraph 2.24 of the Guidance reads as follows:

Historic parks and gardens
Again no additional statutory controls follow from the inclusion of a site in English Heritage's Register of Parks and Gardens of Special Historic Interest (see paragraph 6.38), but local planning authorities should protect registered parks and gardens in preparing development plans and in determining planning applications. The effect of proposed development on a registered park or garden or its setting is a material consideration in the determination of a planning application. Planning and highway authorities should also safeguard registered parks or gardens when themselves planning new developments or road schemes. (Emphasis added).

18.2

While the Council deleted the word "developed", it inserted the word "improved", which does not meet the objection. I do not understand why the Council would wish to resist adopting the words of the national policy. I have suggested that, to accord with national policy, the policy should simply read:

The Council will protect registered parks and gardens in determining planning applications. The Council will seek to ensure that historic parks and gardens are appropriately managed and maintained.

18.3

At the same time, while the Council merely notes that Crystal Palace Park is a Grade II* listed park, I suggest that the opportunity be taken to bring together its designations and reflect its sensitivity:

"Crystal Palace Park is a site of particular sensitivity. It is the only Grade II* listed park in the borough. Most of the Park is a Conservation Area and all of it is Metropolitan Open Land. Any proposed treatment of the Park will need to pay close regard to these designations."

18.4

This suggestion receives peremptory treatment in Bromley's schedule of responses, saying it is a statement of fact which it would be inappropriate to add. No reasons are given why it is inappropriate. In fact, it is entirely appropriate to collect references to the designations of this strategic Park in one place, and to underline that sensitive treatment is required. All of the UDP consists of statement of fact or policy. The fact that something states fact is hardly justification for its exclusion. Furthermore, the Bromley proposal is to tell the public that the top site and the sports centre are development sites, and to describe why this is so. It is very difficult to understand why it would not also wish to underline that strong planning designations are attached to the land.

18.5

Finally, policy BE14 is deficient, in that its commentary refers to the Council's desire to protect major skyline ridges from insensitive development, but the policy itself fails to do so. The current UDP provides in policy E11 that the Council will not normally permit proposals for high buildings which adversely affect strategically important local views … and skyline ridges. It is not understood why that has been dropped from the current version of the policy. I have suggested a perpetuation of the previous policy so as to accord with the proposed commentary:

"The Council will not normally permit development that adversely affects strategically important local views, views of local importance, landmarks and skyline ridges."

18.6

Bromley's response is that the importance of skyline ridges is acknowledged in the commentary and the policy adequately addresses the issue. Of course, the policy does not adequately address the issue, because while the commentary refers to views of borough or local importance, landmarks and major skyline ridges, the policy inexplicably omits the last of these.

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Bromley Unitary Development Plan	Proof of Philip Kolvin
Crystal Palace Park	Crystal Palace Campaign
Section 18

18	Conservation: Objections to Chapter 6 policies. (0296I, 0297I, 0296J, 0297J)
18.1	A further opportunity for protection is lost in policy BE11, which deals with historic parks and gardens. The policy states that the Council will seek to ensure that such places are appropriately managed, improved and maintained, and that development proposals should have due regard to their special characteristics and interest. This misses out a crucial verb in national planning policy PPG15: "protect". Paragraph 2.24 of the Guidance reads as follows: Historic parks and gardens Again no additional statutory controls follow from the inclusion of a site in English Heritage's Register of Parks and Gardens of Special Historic Interest (see paragraph 6.38), but local planning authorities should protect registered parks and gardens in preparing development plans and in determining planning applications. The effect of proposed development on a registered park or garden or its setting is a material consideration in the determination of a planning application. Planning and highway authorities should also safeguard registered parks or gardens when themselves planning new developments or road schemes. (Emphasis added).
18.2	While the Council deleted the word "developed", it inserted the word "improved", which does not meet the objection. I do not understand why the Council would wish to resist adopting the words of the national policy. I have suggested that, to accord with national policy, the policy should simply read: The Council will protect registered parks and gardens in determining planning applications. The Council will seek to ensure that historic parks and gardens are appropriately managed and maintained.
18.3	At the same time, while the Council merely notes that Crystal Palace Park is a Grade II* listed park, I suggest that the opportunity be taken to bring together its designations and reflect its sensitivity: "Crystal Palace Park is a site of particular sensitivity. It is the only Grade II* listed park in the borough. Most of the Park is a Conservation Area and all of it is Metropolitan Open Land. Any proposed treatment of the Park will need to pay close regard to these designations."
18.4	This suggestion receives peremptory treatment in Bromley's schedule of responses, saying it is a statement of fact which it would be inappropriate to add. No reasons are given why it is inappropriate. In fact, it is entirely appropriate to collect references to the designations of this strategic Park in one place, and to underline that sensitive treatment is required. All of the UDP consists of statement of fact or policy. The fact that something states fact is hardly justification for its exclusion. Furthermore, the Bromley proposal is to tell the public that the top site and the sports centre are development sites, and to describe why this is so. It is very difficult to understand why it would not also wish to underline that strong planning designations are attached to the land.
18.5	Finally, policy BE14 is deficient, in that its commentary refers to the Council's desire to protect major skyline ridges from insensitive development, but the policy itself fails to do so. The current UDP provides in policy E11 that the Council will not normally permit proposals for high buildings which adversely affect strategically important local views … and skyline ridges. It is not understood why that has been dropped from the current version of the policy. I have suggested a perpetuation of the previous policy so as to accord with the proposed commentary: "The Council will not normally permit development that adversely affects strategically important local views, views of local importance, landmarks and skyline ridges."
18.6	Bromley's response is that the importance of skyline ridges is acknowledged in the commentary and the policy adequately addresses the issue. Of course, the policy does not adequately address the issue, because while the commentary refers to views of borough or local importance, landmarks and major skyline ridges, the policy inexplicably omits the last of these.